水果膨大剂
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3105510000 | 35.0% | CN | US | Official Doc |
| 3105590000 | 35.0% | CN | US | Official Doc |
| 3105900050 | 35.0% | CN | US | Official Doc |
| 3824993990 | 35.0% | CN | US | Official Doc |
| 3808997000 | 40.0% | CN | US | Official Doc |
AI Analysis
🍎 Fruit Swelling Agents (Plant Growth Regulators/Fertilizers)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition & Classification: Do You Really Understand "Fruit Swelling Agents"?
Fruit swelling agents, also known as plant growth regulators (PGRs) or specific fruit enlargement formulations, are chemical preparations used to promote cell division and expansion in fruits. In international trade, they are often classified under Chapter 31 (Fertilizers) or Chapter 38 (Chemical Products) depending on their specific composition, primary function, and whether they are registered as fertilizers or plant protection products.
Based on the provided , these products fall into four main HS Code categories, primarily targeting the US market with significant "122 Clause" and Section 301 tariffs.
⚠️ Key Classification Distinction:
- If the product is primarily a fertilizer (containing N, P, K) with some growth-regulating properties → Chapter 31 (3105.xx)
- If the product is primarily a chemical preparation/compound (e.g., gibberellins, 2,4-D mixtures) not primarily for nutrition → Chapter 38 (3808.xx, 3824.xx)
- Crucial Note: All listed HS Codes in the are subject to high additional tariffs due to US-China trade policies.
📦 II. HS Code Classification Details (2026 Latest Tariff Rules)
| HS Code | Product Description | Scope & Application | Tax Rate |
|---|---|---|---|
3105.51.00.00 |
Plant growth regulators/fertilizers containing nitrogen and/or phosphorus | PGRs where N/P are primary active ingredients; regulated as fertilizers with growth effects | 35.0% |
3105.59.00.00 |
Chemical fertilizers containing phosphorus, potassium, etc. | Fertilizer blends where P/K are dominant; includes some swelling agents classified as fertigation products | 35.0% |
3105.90.00.50 |
Other fertilizers containing inorganic substances (Residual Category) | Fertilizer-like PGRs that don't fit specific N/P/K subcategories; "catch-all" for inorganic nutrient-based swelling agents | 35.0% |
3824.99.39.90 |
Mixtures of two or more inorganic compounds (Chemical industry preparations) | Complex chemical mixtures used as PGRs, not primarily for plant nutrition but for physiological control | 35.0% |
3808.99.70.00 |
Plant growth regulators/fruit swelling agent preparations containing inorganic substances | Pesticide-grade or regulated PGR preparations specifically for fruit enlargement, often with inorganic carriers | 40.0% |
🔍 Critical Reminder:
- Chapter 31 (3105.xx): Classified as Fertilizers. Lower tax rate (35%) but requires fertilizer registration.
- Chapter 38 (3808/3824): Classified as Chemical Preparations/Pesticides. Higher tax rate for 3808 (40%). Requires EPA/pesticide regulation compliance in the US.
- All HS Codes in the include Section 301 (25%) and Section 122 (10%) tariffs on top of base rates.
💰 III. 2026 Latest Tariff Rate Breakdown (Including Surtaxes & Policy Add-ons)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Time: 2025/2026 (Current Trade War Framework)
🎯 1. HS Codes: 3105.51.00.00, 3105.59.00.00, 3105.90.00.50, 3824.99.39.90
Tariff Rate: 35.0%
| Item | Content |
|---|---|
| Base MFN Rate | 0.0% |
| Section 301 Surtax | +25.0% (Under US Trade Act Section 301) |
| Section 122 Tariff | +10.0% (Under IEEPA Section 122, targeting specific agricultural/chemical imports from China) |
| Total Tariff Rate | 35.0% |
| Tax Calculation | CIF Value × 35% |
| De Minimis Exemption | ❌ Not Eligible (Section 301 and 122 tariffs typically apply even to low-value shipments, denying de minimis) |
| Legal Basis | Section 301: 19 U.S.C. § 2411 → IEEPA Sec 122 → HTSUS: 3105.xx / 3824.xx |
📌 Explanation:
- The 25% is the standard Section 301 tariff on Chinese-origin goods in these chemical/fertilizer categories.
- The 10% is an additional surcharge under "Section 122" (often associated with specific trade remedies or emergency powers for strategic goods).
- Total 35% is a significant cost barrier for exporters.
🎯 2. HS Code: 3808.99.70.00
Tariff Rate: 40.0%
| Item | Content |
|---|---|
| Base MFN Rate | 5.0% |
| Section 301 Surtax | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Tariff Rate | 40.0% |
| Tax Calculation | CIF Value × 40% |
| De Minimis Exemption | ❌ Not Eligible |
| Legal Basis | IEEPA:9903.01.25 → Section 301 → HTSUS: 3808.99.70.00 |
📌 Explanation:
- This HS Code has a higher base rate (5%) because it is classified under Chapter 38 (Pesticides/Herbicides/Plant Regulators), which are more strictly regulated than fertilizers.
- The Section 122 (10%) and Section 301 (25%) are added on top, resulting in the highest total rate of 40%.
- This classification is common for pure plant growth regulators (e.g., Gibberellic Acid formulations) that are not primarily fertilizers.
🛠️ IV. Customs Clearance Practical Advice (Avoiding Pitfalls)
✅ 1. Documentation Checklist (Mandatory)
| Document | Required? | Notes |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must list active ingredients (e.g., Gibberellins, Naphthaleneacetic acid), N-P-K ratios (if fertilizer class), and concentration. |
| ✅ EPA Registration Number (US) | ✔️ | Critical for Chapter 38 (3808.xx). Fruit swelling agents are often regulated as pesticides or biopesticides by the EPA. No EPA # = Seizure Risk. |
| ✅ Certificate of Analysis (COA) | ✔️ | To prove inorganic/organic composition, ensuring correct HS Code (31 vs. 38). |
| ✅ Commercial Invoice | ✔️ | Must clearly state "Fruit Swelling Agent / Plant Growth Regulator" and origin (China). |
| ✅ Fertilizer Registration (if Ch. 31) | ✔️ | If classified under 3105.xx, ensure it meets US state/federal fertilizer standards. |
| ✅ Safety Data Sheet (SDS) | ✔️ | Required for customs and shipping compliance. |
✅ 2. Classification Strategy (Key Tips)
🔥 "Check the Active Ingredient: If it's N/P/K, try Chapter 31. If it's pure PGR (like GA3), it's likely Chapter 38."
| Scenario | Correct HS Code | Tax Rate | Why? |
|---|---|---|---|
| Fertilizer with added growth regulators (N/P/K dominant) | 3105.51.00.00 |
35% | Primary function is nutrition; PGR is secondary. |
| Pure Plant Growth Regulator (e.g., 100% Gibberellin) | 3808.99.70.00 |
40% | Pure chemical PGR, regulated as pesticide/preparation. |
| Mixture of inorganic salts for swelling | 3824.99.39.90 |
35% | Chemical preparation, not primarily fertilizer. |
| Unknown composition "swelling agent" | 3105.90.00.50 |
35% | Fallback fertilizer category if no other fit. |
✅ 3. Special Considerations
| Issue | Advice |
|---|---|
| EPA Compliance | Most fruit swelling agents are EPA-regulated. Importing without EPA registration is illegal. Ensure your supplier has an EPA Establishment Number. |
| Section 122 Risk | The 10% Section 122 tariff is a recent/additional layer. Verify if your product is on the specific list subject to this surcharge. |
| De Minimis Loophole? | ❌ Do not rely on $800 de minimis exemption. Section 301 and 122 tariffs often override de minimis rules for Chinese goods. |
| Labeling | Must comply with EPA labeling requirements (active ingredients, net weight, EPA reg #, establishment #). |
🌍 V. Global Market Comparison (2026)
| Country/Region | Recommended HS Code | Tariff | Key Requirement | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 3808.99.70.00 / 3105.xx |
35%–40% | EPA Registration + Section 301/122 Compliance | Highest tariffs globally. Strict chemical regulation. |
| 🇨🇳 China | 3105.xx / 3808.xx |
5%–10% | Ministry of Agriculture Registration | Lower tariffs, but domestic registration required. |
| 🇪🇺 EU | 3808.94 / 3105.90 |
6.5%–12% | EU Biocides Regulation (BPR) | No Section 301/122, but strict biocide regulations. |
| 🇧🇷 Brazil | 3808.94 |
14%–20% | MAPA Registration | Major agricultural market, high import duty but no US-style surtaxes. |
📌 Conclusion:
- The US market is the most challenging due to the 35–40% effective tariff rate (including Section 301 + 122).
- Compliance cost is high (EPA registration), and tariff cost is prohibitive.
- Consider third-country sourcing (e.g., Vietnam, India) if possible to mitigate Section 301/122 tariffs, but ensure substantial transformation to avoid anti-circumvention rules.
📌 VI. Common Mistakes & Pitfalls (Lessons Learned)
❌ Mistake 1: Declaring as "Fertilizer" (3105) when it's a pure PGR (3808)
👉 Consequence: Customs may reclassify, impose 40% instead of 35%, and delay shipment for EPA verification.
❌ Mistake 2: Ignoring Section 122 (10%) tariff
👉 Consequence: Underpayment of duties → Penalties + Interest at customs clearance.
❌ Mistake 3: Using "De Minimis" ($800) for small samples
👉 Consequence: Seizure if Section 301/122 applies. US CBP increasingly cracks down on this for Chinese chemicals.
❌ Mistake 4: No EPA Registration Number on the label
👉 Consequence: Refused entry, return, or destruction of goods.
✅ Correct Approach:
"Plant Growth Regulator, Gibberellic Acid, 10%, EPA Reg. No. XXXXX-XXX, Net Wt. 1kg, Origin: China."
🎯 VII. Conclusion: Strategic Clearance for Fruit Swelling Agents
🎯 Key Takeaways:
🔹 Tariff Burden: 35–40% is the effective rate. Factor this into your pricing.
🔹 Compliance is Key: EPA Registration is non-negotiable for Chapter 38 products.
🔹 Avoid De Minimis: Do not rely on low-value exemptions for Chinese-origin chemical products.
🔹 Pre-Clearance: Apply for CBP Ruling or EPA Pre-Approval before shipping.
📌 Pro Tip:
If your product is originating from China, explore tariff engineering (can it be classified under a lower-tariff subheading?) or supply chain diversification (assemble/finish in a third country) to reduce the 35–40% tariff impact.
📣 Immediate Action Required:
📞 Consult a Customs Broker to verify EPA status and HS Code classification.
📄 Secure EPA Registration before shipping to the US.
🧮 Calculate Landed Cost including 35–40% duties to ensure profitability.
✨ Professional clearance starts with accurate classification!
💼 Every percentage point of duty impacts your bottom line!
Customer Reviews
About HS Code Classification
The Harmonized System (HS) is an internationally standardized nomenclature developed by the World Customs Organization (WCO) to classify traded products. Over 200 countries use the HS system as the basis for customs tariffs, trade statistics, and import/export regulations.
Each HS code follows a hierarchical structure:
- Chapter (2 digits) — Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) — More specific grouping within the chapter
- Subheading (6 digits) — Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) — Country-specific extensions for further classification, such as US HTSUS 10-digit codes
Correct HS code classification is essential for smooth customs clearance, accurate duty payment, and compliance with trade regulations. Misclassification can lead to customs delays, overpayment of duties, or penalties.
When importing from CN to US, the applicable tariff rates may include:
- Most-Favored-Nation (MFN) rate — The standard duty rate applied to WTO members
- General rate — Applied to countries without trade agreements
- Trade remedy duties — Additional tariffs such as Section 301 (anti-dumping), Section 232 (national security), or countervailing duties
The information provided on this page is for reference purposes only. For official classification, please consult with your local customs authority or a licensed customs broker.